End of the COVID-19 Public Health Emergency - Impact on Medicaid Enrollments

The Federal COVID-19 Public Health Emergency (PHE) is likely to end in the next few months. This event will have a significant impact on state Medicaid programs.

A provision in the Families First Coronavirus Response Act provides continuous enrollment for Medicaid and CHIP beneficiaries for the period of the PHE. States may not dis-enroll any beneficiary who was enrolled in Medicaid as of March 18, 2020, or anyone who newly enrolls until after the national emergency declaration has been lifted. In essence, it provides continuous eligibility to ALL current beneficiaries and new enrollees in Medicaid unless they move out-of-state or request voluntary termination:

https://ccf.georgetown.edu/2020/03/23/families-first-coronavirus-response-act-freezes-disenrollment-in-medicaid/

During the PHE states have suspended renewals and periodic reviews of program eligibility. This allows continuous coverage of beneficiaries, even if income changes or other factors might otherwise lead them to lose coverage. Once the PHE ends, states will re-initiate their eligibility reviews and redeterminations. The Biden Administration has promised states at least 60 days’ notice of any upcoming PHE termination:

https://www.cnn.com/2022/02/17/politics/children-medicaid-public-health-emergency/index.html?utm_campaign=KHN%3A%20Daily%20Health%20Policy%20Report&utm_medium=email&_hsmi=204354484&_hsenc=p2ANqtz-_Cz2DmpA8BZ6i0DaPkRKlvAI-065qSIlCgA2tmohpHnRuNmGMLCY9dhteolBX8YoBn9x5yHkqcTS32_G_G5v-zUf9nPg&utm_content=204354484&utm_source=hs_email

This will allow states several weeks to gear up case reviews and redeterminations. The likely impact of eligibility reviews will be a loss of coverage for millions of people. There will be a need to gear up counseling for affected families, including assessment of eligibility for other coverage. Without this, the numbers of uninsured will swell.

The impact in rural areas could be greater than in urban areas. Rural communities have fewer enrollment assistance resources than do urban areas. Coordination of  state and local responses to the upcoming PHE termination could help mitigate the problem:

https://ccf.georgetown.edu/2022/02/17/millions-of-children-may-lose-medicaid-what-can-be-done-to-help-prevent-them-from-becoming-uninsured/

SORHs could potentially be part of the planning effort to address the issue and its impact in rural areas.

The current PHE is scheduled to expire on April 16, 2022. The Biden Administration is considering at least one more extension of 90 days, with a subsequent expiration date in July. There is Congressional opposition to this extension, but its enactment appears likely. It should be noted that a coalition of community healthcare providers, Medicaid directors and insurers have requested at least a 120-day lead time for changes in PHE provisions affecting Medicaid/CHIP:

https://medicaidplans.org/wp-content/uploads/2022/02/Congressional-Medicaid-Glide-Path-Ltr_Major-Medicaid-Organizations_2_16_22-002.pdf

This would extend the period for states to coordinate efforts to assure continuing coverage for Medicaid beneficiaries.

Date: March 1, 2022

Tags: COVID-19, Medicaid, Public Health Emergency